There is no responsible single turnkey price for every Georgian VASP. An exchange using outsourced custody, a cash-kiosk network, an institutional transfer service and a stablecoin issuer require different people, systems, policies, testing and regulatory evidence.
Budget categories
| Category | What it can include |
|---|---|
| Official fee | NBG registration fee of GEL 5,000. |
| Legal and regulatory | Classification, structure, governance, contracts, application and NBG engagement. |
| Foreign documents | Criminal records, corporate records, apostille/legalisation, certified translation and refreshes. |
| Local substance | Office, management, compliance, operations, finance and support. |
| AML and sanctions | Risk assessment, procedures, configuration, analytics, training, QA and reporting. |
| Technology | KYC/KYB, KYT, custody/wallet, ledger, cases, audit logs, cybersecurity and continuity. |
| Assurance | Penetration testing, security review, internal audit or other independent evidence. |
| Ongoing operations | Reporting, monitoring QA, training, change control, accounting, payroll and tax support. |
Separate preparation from statutory review
The legal 60-day decision period begins after a complete required filing. Assessment, evidence collection, operational build, testing and translations happen before that point. NBG questions and material model changes can add further work.
Common causes of delay
- Opaque or changing ownership.
- Late foreign criminal records or company documents.
- Administrators unable to evidence competence or reputation.
- Undefined counterparties, corridors or transaction flows.
- Generic policies disconnected from system behaviour.
- Technology unable to demonstrate customer, transaction, monitoring and audit flows.
- Weak financial projections, staffing or provider evidence.
Legal review required before production publication Regulatory baseline: 22 August 2026 Requirements depend on the exact model